2026 Predictions based on February 10 CRS Report on Federal IDR

Last week I analyzed a few consecutive quarters of CMS Federal IDR Public Use Files and the data told a pretty clear story: dispute volumes were continuing to accelerate, facilities were scaling filings, and outcomes above the Qualified Payment Amount were maintaining at a consistently high level.

On Feb 10, the Congressional Research Service (CRS) released a report (R48851) that adds an additional dimension, comparing IDR outcomes not just to QPA, but to actual in-network negotiated rates. 

Below are three insights on the CRS report that can help your team plan your next steps. 

But first, full disclosure: Macedon makes an Award-winning NSA Automation Software.  Schedule a chat with me if you would like to know more.

Insight 1:  IDR Outcomes Are Frequently Well Above In-Network Negotiated Rates

Prior analysis focused on the fact that 84% - 88% of determinations exceeded QPA across Q4 2024 through Q2 2025. The CRS report expands that frame by benchmarking prevailing offers against in-network emergency service rates.

In CRS’ 14-state sample of emergency service disputes, they found that over 95% of prevailing offers were above the median in-network rate. The median prevailing offer across that sample exceeded the in-network median by more than 3x. And in at least one state, the median prevailing offer exceeded 6x the in-network rate.

This is a materially different benchmark than QPA. It suggests that, in certain markets, IDR determinations may not be only modestly above payment anchors but instead, examples now exist where determinations are well above prevailing commercial rates. 

Why This Matters:  The question is no longer only whether IDR exceeds QPA. It is whether IDR outcomes are influencing broader pricing expectations relative to negotiated market rates. 

Insight 2:  State-Level Variation Is Significant

The CRS report also highlights meaningful geographic variation. In some states, median prevailing offers were only modestly above negotiated in-network rates, approximately 118% to 129%. In others, the gap was dramatically wider.

Our prior analysis was national in scope, focusing on aggregate CMS trends. The CRS findings suggest that national averages may mask significant state-level differences in how IDR outcomes compare to commercial pricing benchmarks.

Why This Matters:  For payers and providers operating in multiple states, IDR economics may vary materially by geography. A strategy that works in one state may not translate directly to another. 

Insight 3:  The Magnitude of the Differential May Shape Market Behavior 

The CMS data showed sustained volume growth of 34% across three quarters, with more than 641,000 disputes initiated in Q2 2025 alone. The CRS report adds context by showing that, at least for emergency services, prevailing offers often sit well above negotiated benchmarks.

When high volume is paired with sizable differentials relative to market rates, the incentives become clearer. Providers have reason to continue filing. Payers face growing exposure. And policymakers may view the system through a different lens if IDR outcomes are seen as materially exceeding negotiated pricing norms.

Why This Matters:  The CRS report reframes the discussion from administrative mechanics to market impact. That shift could influence future regulatory and legislative attention. 

My prediction

The CRS report does two things: it (a) confirms prior analysis about scale, participation, and outcome consistency with the IDR process, and (b) it layers on a clearer view of how IDR outcomes compare to negotiated in-network rates.

If the CMS data shows that IDR is scaling (which it does), the CRS report signals that the revenue impact for both payers and providers may be stronger than initially assumed.

As more data comes out and regulatory conversations continue, the real focus will shift to how dispute volume, QPA outcomes, and negotiated in-network market rates interact. That dynamic is where the next phase of the IDR debate will play out.

Want to continue the discussion? Schedule a chat with Seth.